Memorandum Findings of Fact and Opinion
DRENNEN, Judge:
Respondent determined a deficiency of $79,372.46 in petitioner's Federal income tax for the taxable period January 1, 1976, to May 29, 1976.
The following questions are presented for our consideration:
(1) Whether payments made by petitioner to certain individuals during the taxable period at issue reflect amounts which may be deducted under section 162, section 165, or section 166....
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